Melvin Ray Hassell - Page 13

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               day notification period.  These time periods were met                  
               in this appeal.                                                        
               IRC 6330(c) allows the taxpayer to raise any relevant                  
               issue relating to the unpaid tax or the NFTL or Notice                 
               of Intent to Levy at the hearing.                                      
               This Appeals Officer has had no prior involvement with                 
               respect to these appealed liabilities.                                 
               2.  Issues raised by the taxpayer;                                     
               Underlying liability or amount of liability                            
               Taxpayer is disputing the tax liability.  In cases                     
               where the Department of Justice (DOJ) have previously                  
               reduced a liability to judgment Appeals has no author-                 
               ity to compromise a liability or reconsider the liabil-                
               ity issue which includes taxpayer’s challenge to the                   
               collection statute of limitations.  Further, Appeals                   
               does not have the authority to consider any offer                      
               involving the release of federal tax liens or withdraw-                
               als.  Accordingly, since DOJ has previously reduced                    
               this taxpayer’s liability to judgment, Appeals does not                
               have authority to consider the liability issue.                        
               The underlying liability is sustained.                                 
               Collection Alternatives                                                
               Taxpayer did not propose any acceptable collection                     
               alternatives.  When the Notice of Federal Tax Lien was                 
               filed it was appropriate.  The liability was valid and                 
               outstanding.                                                           
               3.   Balancing of need for efficient collection with                   
                    taxpayer concern that the collection action be no                 
                    more intrusive than necessary.                                    
               We believe the filing of the Notice of Federal Tax Lien                
               balances the need for efficient collection of taxes                    
               with concerns that the collection action be no more                    
               intrusive than necessary.  [Reproduced literally.]                     
               Petitioner filed a petition with the Court with respect to             
          the notice of determination.  The petition contained statements,            






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Last modified: May 25, 2011